People v. Chaves G.R. No. L-19521. October 30, 1964

Facts: Esteban Chaves has been found guilty by the CFI and CA of a violation of RA 145. He collected a claim for Marcela Rambuyon for death benefits in the sum of $4,252 due for the demise of her son, a USAFFE veteran. The check was cashed by Chaves and gave only P3, 202.20 to the claimant and retained P5, 362.20 for himself. He was sentenced to indemnify the offended party the sum of P5, 362.20 and costs. However, the indemnity has not been paid yet. So the sheriff resorted into taking a residential lot and building of the accused. The accused claimed that it was a recorded family home extra-judicially.

Issue: Whether or not, the family home extrajudicially constituted is entitled to exemption from the execution levy issued at the instance of the offended party.

Held:  No.

Ratio: Article 243, paragraph 2 of the Civil Code provides that debts incurred before the declaration was recorded in Registry of Property shall be exempted. However, the Supreme Court ruled that it is of no merit that the appellant considered his unpaid indemnity due as a debt, and that, the word “debt: shall be treated in its generic sense.

StatCon maxim: The context may circumscribe the meaning of a statute; it may give a word or phrase a meaning different from its usual or ordinary signification. In such a case, the meaning dictated by the context prevails.